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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
Address1 | P.O. BOX 2600 |
Address2 |
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City | VALLEY FORGE |
State | PA |
Zip Code | 19482 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 291058-12
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6. House ID# 371950000
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TYPE OF REPORT | 8. Year | 2016 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
10. Check if this is a Termination Report | Termination Date |
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11. No Lobbying Issue Activity |
INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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12. Lobbying | 13. Organizations | ||||||||
INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
Signature | Digitally Signed By: Alex Hula |
Date | 10/20/2016 4:49:14 PM |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code FIN
16. Specific lobbying issues
Issues arising from Dodd-Frank regulations - including systemic risk regulation of non-bank financial institutions, FSOC process improvements, SIFI designations for non-bank financial institutions, and approaches to reducing systemic risk in the financial system (including the Financial Stability Oversight Council Improvement Act of 2015 - H.R. 1550 - and Section 302 of the Financial Regulatory Improvement Act of 2015 - S. 1484)
Issues related to systemic risk standards being developed by the Financial Stability Board (FSB) and the International Organization of Securities Commissions (IOSCO) for mutual funds and fund companies
Issues related to the Office of Financial Research and its analysis of asset managers and mutual funds
Issues related to money market fund operations and regulations, including the Consumer Financial Choice and Capital Markets Protection Act of 2015 (S. 1802)
Issues related to private label securitization market and appropriate benchmarks
Issues related to the management of ETFs, including portfolio transparency, custom basket rules and usage of custom baskets, and general rulemaking and policy guidance on ETFs
Issues related to municipal bonds and other securities and the structure of the municipal securities market, including issues related to bankruptcy
Issues related to equity market structure matters, including trade-at, Regulation NMS reform, minimizing latency of market data feeds, improving resiliency of technology and infrastructure to avoid single points of failure, access fees, the maker-taker model, ETF trading, limit-up/limit-down, and reopening processes
Issues related to a pilot program for expanded tick sizes for small capitalization stocks
Issues related to monetary policy
Issues related to existing and potential financial services, investment offerings and asset management
Issues related to proposed margin rules for uncleared swaps, including eligible collateral, initial margin thresholds, variation margin and segregation of margin
Issues related to supplemental leverage ratio
Issues related to security-based swaps reporting
Issues related to swap clearinghouse risks and swap execution facility liquidity
Issues related to cross border derivative trading provisions
Issues related to ISDA Resolution Stay Protocol
Issues related to legislation and regulations affecting mutual funds and the mutual fund industry
Issues related to the availability and management of liquidity in the fixed income markets
Issues related to the structure of the fixed income markets, including the Treasury market
Issues related to the harmonization of standards of care for Registered Investment Advisers and Broker-Dealers (Dodd-Frank Act Section 913)
Issues related to modernization of mutual fund information reporting and enhanced portfolio disclosure
Issues related to operational risk in the asset management industry
Issues related to liquidity management rules for mutual funds and ETFs, including swing pricing
Issues related to funds' use of derivatives
Issues related to corporate governance
Issues related to SEC rulemaking toward electronic delivery of mutual fund disclosures
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Securities & Exchange Commission (SEC), Treasury - Dept of, Federal Reserve System, Federal Trade Commission (FTC), Commodity Futures Trading Commission (CFTC)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Jerry |
Golden |
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Jillien |
Flores |
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Alex |
Hula |
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Ann |
Combs |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code RET
16. Specific lobbying issues
Issues in support of the Receiving Electronic Statements to Improve Retiree Earnings Act (H.R. 2656 and S.3417) to provide for electronic delivery of ERISA-mandated statements and disclosures
Issues related to the Department of Labors proposed fiduciary standard and the delivery of investment advice or guidance to investors in qualified retirement plans
Issues related to tax incentives for retirement savings; encourage retention of current tax incentives
Issues related to employee benefit plan administration
Issues related to MyRA
Issues related to limitations on retirement plan contributions or assets
Issues related to the DOL's budget proposal and the agency's views on state-based retirement plans for private sector workers
Issues related to multiple-employer retirement plans
Issues related to retirement coverage proposals
Issues related to removing the prohibition on 403(b) plans investing in collective investment trusts
Issues related to expanding relief under IRS Employee Plans Compliance Resolution Systems (EPCRS)
Issues related to auto-enrollment safe harbor
Issues related to improving, simplifying, and enhancing retirement plans
Issues related to lifetime income options
Issues related to federal budget implications for retirement and health benefits
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Labor - Dept of (DOL), Government Accountability Office (GAO)
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Jerry |
Golden |
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Jillien |
Flores |
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Alex |
Hula |
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Ann |
Combs |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code TAX
16. Specific lobbying issues
General tax issues related to mutual funds
Commodity related investments, savings
Capital gains and dividend tax rates as they relate to mutual funds
Security or financial transaction tax proposals, including the Inclusive Prosperity Act of 2015 (H.R. 1464 and S. 1371) and the College for All Act (S. 1373)
Issues related to limitations on exclusion of municipal bond interest
Issues related to the impact of tax reform proposals on the municipal bond market and issuers
Issues related to 529 college savings plans; encourage retention of 529 plan tax incentives
Issues related to allowing the payment of qualified elementary and secondary education expenses from 529 college savings plans, including the Empowering Parents to Invest in Choice Act (H.R. 1928)
Issues related to mobile workforce legislation, including the Mobile Workforce State Income Tax Simplification Act (S. 386, H.R. 2315)
Issues related to legislation that would impact the American Opportunity Tax Credit and 529 Plan contribution eligibility
Issues related to tax incentives for retirement savings
Issues related to the excise tax on the excess benefit portion of high-cost employer sponsored health care plans (known as Cadillac plans), including the Ax the Tax on Middle Class Americans' Health Plans Act (H.R. 879).
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Jerry |
Golden |
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Jillien |
Flores |
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Alex |
Hula |
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Ann |
Combs |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code HOM
16. Specific lobbying issues
Cybersecurity Issues (e.g., information sharing abilities, data breach notifications, enforcement actions, and related matters) including the Cybersecurity Threat Sharing Act of 2015 (S. 456), the Data Security and Breach Notification Act of 2015 (S. 177), the Cyber Intelligence Sharing and Protection Act (H.R. 234), the Cybersecurity Information Sharing Act of 2015 (S. 754), the Protecting Cyber Networks Act (H.R. 1560), the National Cybersecurity Protection Advancement Act of 2015 (H.R. 1731), and the Data Accountability and Trust Act (H.R. 580)
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES, Treasury - Dept of
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Jerry |
Golden |
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Jillien |
Flores |
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Alex |
Hula |
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Ann |
Combs |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code BUD
16. Specific lobbying issues
Issues related to reductions in the federal debt and federal budget deficit
Issues related to raising the debt ceiling and avoiding federal government default
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES
18. Name of each individual who acted as a lobbyist in this issue area
First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Jerry |
Golden |
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Jillien |
Flores |
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Alex |
Hula |
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Ann |
Combs |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
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21. Client new principal place of business (if different than line 20)
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
Name | Address |
Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
1 | 2 | 3 |
FOREIGN ENTITIES
27. Add the following foreign entities:
Name | Address |
Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
1 | 3 | 5 |
2 | 4 | 6 |